Privacy Policy
Last Updated On 01-Jan-2023
Effective Date 01-Jan-2023
Background
Polpo Play AB, ID no. 559318-5712 (“Polpo”, “we”, “us”) are passionate about the privacy of our listeners, customers, and digital users. Consequently, we want to use this privacy policy to clearly and transparently describe how we collect, use, transfer, and store personal data.
Polpo’s activities primarily consist of the production and provision of podcasts. Note, therefore, that the EU’s General Data Protection Regulation is not applicable to the extent that it would contravene the Fundamental Law on Freedom of Expression.
Data controller
Polpo is the data controller for the processing of personal data on this and other websites run by Polpo on Polpo’s mobile apps, and in other services provided by Polpo. Consequently, Polpo is obliged to ensure that all processing is in accordance with this policy and all applicable legislation.
Contact information
Should you have any questions regarding Polpo’s processing of personal data, you can contact us using the details below.
E-mail: privacy@polpoplay.com
Address: Polpo Play AB, Postbox 2, 414 51 Göteborg, Sweden
Data we process
When using our digital services including our websites
When using our digital services such as our apps and websites, we collect the data we need to provide the service to you, as well as data on your use of the service or website. This includes your IP address or device ID (app), as well as other technical information such as traffic provider, browser version, and operating system. We also collect information via cookies. For more information about cookies, please refer to our cookie policy.
When registering an account at Polpo Play APP
When registering an account, we collect your e-mail address. You will also be requested to register a username. When using the service while logged in, we also collect data such as user history in order to improve the service as well as the content and advertising experience. All Polpo Play data is processed only for registered accounts once consent has been given.
Data collected by way of personal contact
We collect personal data from you when you contact us, such as when contacting our sales department. First and foremost, we collect the personal data we need to answer your query or handle your case, such as your name and phone number. Depending on how you choose to contact us, we may also collect your e-mail address or home address.
How do we process personal data?
General
Polpo collects, processes, and stores personal data only in a way that is legal, correct, transparent, and appropriate and only to the extent necessary. Polpo will process personal data only in a way that does not infringe on the individual’s personal privacy. Polpo is always careful to protect personal data by way of appropriate security measures when processing personal data.
In order to provide, improve, and develop our services
Data collected when using our services is used to facilitate the stable provision of the service/website, and to measure, analyse, and develop Polpo’s products.
In order to communicate with you
The data may also be used to communicate with you and answer you when you contact us.
In order to adapt content and advertising for you
We use the data we collect on you as well as data we collect when you use our services while logged into your account to evaluate your use of our services and to adjust the way our website content looks when you visit or use our digital services. This is known as profiling. This adaptation may include saving and displaying information about the podcasts you have listened to, and showing ads, promotions and recommendations that we think suit you and your preferences.
In order to promote safety and security
We use the information we hold in order to verify accounts and activities and to promote the safety and security of our services. We use security solutions to protect accounts and in turn increase your security.
In order to fulfil an agreement with you
Where there is a customer or supplier agreement between us, we process only the personal data that is relevant to the customer relationship and which is required to fulfil the agreement. Personal data such as the representative’s name, e-mail address, and phone number is processed in order to manage the agreement and enter into dialogue with the customer. Personal data such as personal identification number or driving licence details is processed only if necessary for billing or credit rating purposes or the like.
In order to comply with legal requirements
Personal data may also be processed in order to fulfil various legal obligations in relation to security and accounting, for example.
Sharing data with third parties
In order to provide our services to you and to run our business, in some situations we may need to share your personal data with third parties. When we do this, we always ensure a high level of security and full legal compliance.
Where Polpo transfers personal data to a third party that shall process it on Polpo’s behalf, thus making it Polpo’s data processor, Polpo will always conclude agreements that regulate the transfer and processing of the data. Polpo remains responsible for the data and our data processors may process the data only in accordance with the agreement and our instructions.
We will not sell, transfer, or otherwise disclose data beyond what is stated in this policy, unless we are obligated to do so by law or we have your consent for such a transfer.
Sharing with providers of IT services and systems
Our business uses a number of different IT services and systems. Personal data is stored and processed in some of these. Some systems are cloud-based or installed with one of our suppliers. This means that we transfer personal data to the supplier. In these cases, the supplier is our data processor and processes the data on our behalf according to our instructions.
Sharing with partners for compiling information, market analyses, market research, and marketing
In order to develop our business and provide you with more targeted information, services, and offers, we use partners to compile information, market analyses, market research, and marketing. We share some personal data with these partners in order to do this.
Sharing with public authorities
In some cases, we may be required to share your personal data with state and public authorities in accordance with the applicable law.
Transfer to countries outside the EU/EEA
The personal data we collect from you may be transferred to or stored in a country outside the European Economic Area (EEA). The data may also be processed by organisations operating outside the EEA who work with us or one of our suppliers.
Should this be the case, we ensure your personal data is adequately protected and processed in accordance with this policy. This protection includes, but is not limited to, appropriate contract clauses such as standard contractual clauses approved by the European Commission and other appropriate security measures.
Storing of personal data
We store your personal data only for as long as is necessary for the purposes stated in this policy. We adhere to good practice in the industry and existing recommendations and guidelines. Once the purpose for the processing of the data has ended, we securely delete your personal data.
Your rights
Right to revoke consent
Where processing is based on your consent, you have the right to revoke this consent at any time by contacting us. Such revocation does not affect the legality of our processing of your personal data prior to your revocation of your consent.
Right of access and information
You have the right to contact us in our role as a data controller and request access to the personal data that Polpo processes about you, and to be given information about the purposes of our processing and the parties that have received your personal data. As a data controller, Polpo must provide you with a free copy of the personal data that we process. Polpo may charge an administration fee for any additional copies. In responding to such a request, we may ask for proof of your identity, to ensure that we do not send you personal data to another person. We will respond to any requests as soon as possible, but at least within 30 days.
Right of rectification and right of erasure
We want to ensure that the personal data we hold on you is correct and up to date. If any of the data is incorrect, please tell us. You can ask to have your personal data corrected at any time. We will correct any such data without undue delay.
In addition, you have the right to have your personal data erased, such as if it is no longer necessary, or if its processing is based on consent which has been revoked.
Right to limit processing and the right to object to processing
In some circumstances, you have the right to request that the processing of your personal data be limited and, at any time, object to the processing of your personal data if the legal basis for its processing consists of a general interest or balancing of interests, or if your personal data is processed for the purpose of direct marketing.
Right to data portability
If technically possible, and if the legal basis for the processing of your personal data consists of consent, or if the processing has been necessary in order to fulfil an agreement, in some circumstances you have the right to obtain your data and transfer it to another data controller.
How to exercise your rights
To exercise your rights, contact our support team at privacy@polpoplay.com. We are usually required to process your request within one month. Since we are required to check that your request is really being made by you, it must include your name and personal identity number. We may also require a written and signed request from you or other identification information.
Cookies
A cookie is a text file stored on your device when you visit us via a web browser (e.g. polpoplay.com). For more information on how cookies are used and how you can adjust your browser settings to turn off cookies, please read our cookie policy.
Complaints and the right to complain to the Swedish Authority for Privacy Protection
You can contact us if you have complaints regarding how we collect, store, and process personal data. We always strive to resolve any issues you may have, but if you’re unhappy, you can always turn to the Swedish Authority for Privacy Protection (https://www.imy.se).
Changes to this privacy policy
We reserve the right to amend and update this policy. Changes may result from new legal requirements or recommendations or from new services. We recommend that you familiarise yourself with this policy on a regular basis.